Should we be sending the SCRA Notice on open end credit as well as closed end? All I've been able to find in my research is that we should be sending the notice to delinquent borrowers within 45 days after the missed due date of a mortgage loan payment. Not very clear! I'm thinking that the automated system generation of this notice should be based on the collateral type, rather than the loan type.

I'm not aware of any exclusion for open-end credit from the definition of a home loan.

http://www.federalreserve.gov/boarddocs/supmanual/cch/home.pdf

That was my conclusion as well. Thank you!!